Treasury Department Amends Special Measure to Allow Liquidation of CIBanco
Financial Crimes Enforcement Network
The original June 2025 order identified the Mexico-based commercial bank CIBanco as a primary money laundering concern connected to illicit opioid trafficking by organizations such as the Gulf Cartel, the Beltran-Leyva Organization Cartel, and the Cartel Jalisco Nueva Generación.
Under the authority of the FEND Off Fentanyl Act, FinCEN initially prohibited covered financial institutions from engaging in fund transmittals involving the bank.
Following intervention by the Government of Mexico to take over and dissolve CIBanco, this amendment establishes a targeted carve-out to the existing prohibition.
It explicitly authorizes transmittals of funds that are ordinarily incident and necessary to facilitate the Mexican government's liquidation of the financial institution.
The rule allows for the safe unwinding of CIBanco's major assets without triggering U.S. financial penalties.
Covered U.S. financial institutions can process specific transactions related to the bank's dissolution, provided they meet strict oversight criteria.
The broader prohibition on general fund transfers to or from CIBanco remains fully intact.
This exemption applies exclusively to transactions tied to the official liquidation process.
For a transaction to be legally permissible under the amendment, the Government of Mexico's appointed liquidator must officially determine that the specific transmittal is necessary to liquidate CIBanco.
Additionally, the transmittal must not violate any other existing laws or prohibitions.
